TRIP Targeted Research & Intelligence Programme Positive Preparations A review of housing targets and Local Plans March 2014 Executive Summary The NPPF was introduced two years ago as part of the Government’s attempt to make the planning system less complex and more accessible. While one of the key aims of introducing the NPPF was to simplify and speed up the planning process, two years down the line progress on getting submitted Plans found sound appears to have slowed. A review of the 109 Local Plans that have been examined or submitted for examination since the NPPF was introduced confirms that the key reason Plans have stalled is the policy requirement to meet objectively assessed needs, with the housing target remaining the key battleground at examinations. Just over half of Plans propose less housing than had been proposed by former Regional Strategies, but a third of sound plans end up having to increase their target to pass examination. Half of the plans submitted for examination since the NPPF have experienced delays. Progress of many plans has stalled as LPAs take stock of their evidence base before proceeding with the rigorous examination process. The number of Plans being withdrawn has increased in 2013/14 compared to 2012/13. The review suggests eight core typologies of local plan each with their own strategy risks and requiring different approaches to evidence, preparation and examination from both local authorities and those in the development sector: Positive Preparations Underbounded Growers Evidenced full needs and seeking to meet them head on. Unmet needs, but already built up to the boundary or constraints. Squeezed Inbetweeners Unbalanced Strategies Unconstrained locations, near constrained growth areas, which have to respond to pressures. Economically ambitious but without the housing to support it. Lacking Evidence Defer the Pain Out-of-date, insubstantial or no evidence on objectively assessed housing needs. Chasing an ‘early review’ as a solution to unmet needs, with the hope of future change in evidence/politics. Pleading Constraints Zombie Plans Accepting needs but praying in aid of constraints (e.g. Green Belt, SPA, AONB, Infrastructure, Countryside). High housing needs, but no new Local Plan on the horizon and reliance on a pre-NPPF Core Strategy. The Review in Figures 109 40 15 48% 4 1/3 16 Local Plans examined or submitted for examination Local Plans found sound Local Plans withdrawn on the basis of soundness concerns of the 54 ongoing Local Plans have experienced delays and require modifications Additional number of months that it takes on average for Local Plans to be Found Sound Post-NPPF of LPAs had to increase their submitted housing target in order to be found sound Local Plans submitted for examination post-NPPF and have been ongoing for a year or more Positive Preparations iii Introduction It is now two years since the NPPF was published, yet data from the Planning Inspectorate on the progress of Local Plans indicates that over half of Local Authorities still have yet to formally publish new Local Plans since the changes to the planning system were made (illustrated by the red shaded areas in Figure 1). Just 13% of local authorities have an NPPF-compliant up-to-date adopted Plan. Around a quarter have a plan submitted and an examination underway or forthcoming. The remainder, by definition, have no up-to-date plan and applications for planning permission for housing will be subject to the NPPF. A revitalised economy is reinforcing the development industry’s appetite to build, and given the extent of England’s housing crisis and the policy stipulations of the NPPF that Local Plans must positively seek opportunities to meet the objectively assessed need for new homes, housing figures are under deep scrutiny in public examinations. This will mean that the issue of local housing will continue to be a common feature of the planning debate for years to come and as LPAs continue to update their Local Plans to comply with the new system, all parties will continue to require evidence to back up their position at examinations and beforehand. The new National Planning Practice Guidance provides welcome assistance in this regard. This report, which updates a similar NLP study from last year , reviews progress on Local Plan preparation, assesses what has happened to housing targets during the process of plan preparation, and identifies some common themes in the form of eight typologies of local plan area, based on experience to date. Figure 1: Local Plan Progress, as at March 2014 24.7 55.1 7.1 13.1 Pre-NPPF Local Plan or No Local Plan Local Plan Published/ Submitted for Examination Local Plan Found Sound / Adopted Post-Final NPPF Local Plan Found Sound / Adopted Post-Draft NPPF Positive Preparations 1 1 Objectively Speaking: A review of Local Plan examinations, April 2013 Local Plans Two years under the NPPF 40 109 Plans submitted /examined Post-NPPF to immediate 25% Subject / early review Found Sound 48% Require Modifications 54 Ongoing more evidence 69% Require of objectively assessed housing need 15 reason withdrawn 27% Main due to failure to meet duty to cooperate Withdrawn reason withdrawn 73% Main due to housing numbers Figure 2: Tracking Local Plan Progress Post-NPPF Summary of Local Plan Progress since the NPPF came into play Since the National Planning Policy Framework (NPPF) was introduced on 27 March 2012 109 plans have been examined or submitted for examination outside London (Figure 2). Of these, just 40 (37%) have been found sound and a quarter of these are subject to immediate or early review. In most cases the focus of the early review for these plans is to check that they meet objectively assessed needs for housing. In the two years since the NPPF fifteen councils have withdrawn their Plans with the main reason for almost three quarters (73%) of these being in relation to the provision of housing. The remaining 54 Plans are ongoing. However, almost half of these (48%) have experienced delays and require further modifications to their original submitted plans. Of the 26 Plans that require modifications, 18 (69%) of these specifically require more evidence of objectively assessed housing need. The slow progress for half of the submitted Plans since the NPPF is partly because Local Plan making is in the midst of an ‘evidence arms race’ as all parties involved seek to present the strongest evidence on housing need – drawing on the latest data and increasingly refined assumptions on the smallest detail - as ammunition for the examination process. Positive Preparations 2 2 Generally, for plans that were found sound during the period when the NPPF coexisted with Regional Strategies. Time it takes for plans to get through is increasing On average it now takes four months longer for Plans to be found sound after being submitted than it did before the NPPF was introduced (Figure 3). Plans that were submitted and examined prior to the NPPF took on average 10 months from submission to being found sound. A review of the 40 plans (outside London) that have been found sound post-NPPF reveal that the process has taken on average nearly 14 months from submission to being found sound. During this time a third of Plans required modifications to their original submission. Further work and amendments, subsequent consultation and examinations prolonged the process for these plans to be found sound and ultimately adopted. Submission Pre-NPPF Post-NPPF Found Sound 9.7 months 13.7 months Figure 3: Average time from Local Plan Submission to being Found Sound Positive Preparations 3 Almost half of ongoing plans require further work Figure 4 highlights the areas of the country where councils have experienced delays of a year or more in the process of Local Plan examination. Almost half of the Plans ‘in the system’ require further modifications. Progress has stalled in the majority of these cases (69%) due to Inspectors requiring more evidence of objectively assessed housing need. While the reasons for suspending the examination process vary on a case-by-case basis, the majority of councils have been required to reassess their housing numbers. The need for further modifications has drawn out the examination process for 16 (30%) of the 54 ongoing plans for over a year. Over half of these councils’ have had their examination process suspended for 6-12 months while further work was undertaken to deal with the issues raised by the Inspector concerning the soundness of plans, particularly relating to housing requirements. The greater length of time to get plans through the system is down to LPAs recognising the need to build up the evidence base, and where necessary revise their local policy, as required to support their housing target submissions under the new planning policy. Figure 4: Plans in Waiting 2 years 11 months 1 year 10 months 1 year 8 months 1 year 8 months 1 year 6 months 13 1 year 6 months 1 year 5 months 6 1 year 3 months 5 1 year 3 months 7 16 12 10 8 1 year 3 months 11 3 1 year 2 months 1 year 2 months 14 2 15 Bath & North East Somerset 2 East Hampshire 3 Wiltshire 4 Rother 5 Warrington 6 Ribble Valley 7 Rushcliffe 8 South Northamptonshire (South Northants JCS) 9 Northampton (South Northants JCS) 10 Daventry (South Northants JCS) 9 1 year 2 months 1 1 1 year 4 1 year 1 year 11 South Summerset 12 North Warwickshire 13 Richmondshire 14 East Dorset 15 Christchurch 16 Lichfield Map to the left and chart above highlight Councils whose plans have been submitted for examination and have been ongoing for a year or more post-NPPF Positive Preparations 4 Positive Preparations 5 Upward pressure on housing targets In the first year of the NPPF, ten (53%) of the 19 Plans found sound proposed a reduction against the RS target at submission stage, with the remainder being in line with the RS (Figure 5). During the examination process eight required an increase to housing targets after submission. By comparison in the second year of the NPPF, eight (38%) of the 21 Plans found sound proposed a reduction against the RS target at submission stage, indicating a greater proportion of LPAs submitting figures in line or above the RS. During the examination process five required an increase to housing targets after submission. The outcome among the 40 Plans found sound since NPPF has been that only nine (23%) were found sound with a reduced target against their RS target, with three of these (Milton Keynes, Bournemouth, Taunton Deane) justified by the virtue of being above CLG household projections and therefore meeting an objective assessment of housing need. Only six (15%) of the 40 Plans found sound since the NPPF was introduced have had an outcome of a reduction against the RS target and a target below the CLG household projections. Of these, over half are subject to the requirement for early review with a focus on the housing target. Analysis of the Plans found sound within the two years of the NPPF indicate that initially many local authorities aspired to reduce their housing requirement, with over half of Local Plans submitted in the first year of the NPPF having housing targets below the RS. However given the intense debate over housing at examinations and the fact that housing numbers are often the most stringently assessed and contested parts of the Local Plan, this has led to further revisions and modifications and ultimately the majority of Plans at least meeting their RS target. In the second year of the NPPF 13 Plans, representing 62% of the Plans found sound in that year, proposed housing targets above or in line with the RS. The outcome for year two of the NPPF resulted in over three quarters of Plans (16) adopting targets that met or exceeded the RS. Over half of these (9) were found sound with a housing target that meets or exceeds both the RS and CLG household projections target. In the second year of the NPPF fewer plans have required an increase to housing targets after submission. While 42% of the 19 plans found sound in the first year required an increase, only 29% of the 21 in the second year had to raise housing numbers after submission (see Figure 7). RS Targets NPPF Year 1 April 2012 - March 2013 NPPF Year 2 April 2013 - March 2014 CLG HH projections* 47% 53% Proposed RS figure 43% Proposed RS figure Proposed a reduction on RS 19% 38% Proposed RS figure Proposed a reduction on RS 47% Proposed RS figure 57% Proposed RS figure 53% Proposed a reduction on RS 5% 53% Proposed Proposed a the same reduction on RS Figure 5: Proposed housing targets compared to RS and Household Projections Positive Preparations 6 * Figures against relevant HH projections for review period. Plans submitted for examination in NPPF Year 1 were reviewed against 2008 HH projections. Plans submitted for examination in NPPF Year 2 were reviewed against 2011 HH projections. Meets / exceeds Regional Strategy target Meets / exceeds household projections Percentage of sound Local Plans NPPF Year 1 (April 2012 0 March 2013) NPPF Year 2 (April 2013 - March 2014 42% 43% 11% 5% 37% 33% 11% 19% Figure 6: Housing Targets in Sounds Plans in Years 1 & 2 post-NPPF NPPF Year 1 April 2012 - March 2013 19 58% No change to housing Targets after submission 42% Required increase to housing targets after submission 71% No change to housing Targets after submission 29% Required increase to housing targets after submission (11) Plans found sound (8) NPPF Year 2 April 2013 - March 2014 21 Plans found sound (15) (6) Figure 7: Submitted housing targets vs adopted housing targets for Local Plans found sound post-NPPF Positive Preparations 7 More plans are failing the Duty to Cooperate There are also signs of increasing pressure on localities to make the duty to cooperate process work more effectively. As the remnants of the RS fade away, clear evidence of cooperation with surrounding Authorities is becoming an integral concern for many Inspectors’ reviews of Plans. In the second year of the NPPF three plans were withdrawn over their failure to meet the duty to cooperate with neighbouring councils. By comparison none of the plans withdrawn in the first year were primarily due to failure to meet duty to cooperate. A further four plans that have been submitted for examination in the second year of the NPPF have become unstuck due to duty to cooperate. Positive Preparations 8 LPAs must effectively account for cross-boundary issues in their Plans; and even if authorities better get to grips with the statutory process of the legal duty, the underlying soundness of meeting needs across a housing market area remains a concern in situations where constraints on delivery in one area impose unmet requirements on another. The ‘London dimension’ (arising from the current draft Further Alterations to the London Plan, with a housing target set well below levels of need) poses perhaps the greatest challenge in this regard. Positive Preparations 9 Positive Preparations Typologies of Local Plan What issues are likely to emerge in the future for housing targets in Plans? Reviewing the issues frequently debated at examinations, some common themes emerge which suggest a range of Local Plan typologies, each characterised by the risks to the soundness of the strategy put forward. Figure 8 (opposite) outlines these typologies, from the ‘underbounded growers’ who haven’t got the space to deliver the housing they need, to the ‘lacking evidence’ who don’t know what their need is (or deny that it exists) and the ‘pleading constraints’ who may acknowledge their need but assert that they can’t deliver due to their insurmountable constraints. In reality, there are many Local Plans which are straddling numerous typologies, either through coincidence or by design. Each typology brings with it risks to the overall strategy for meeting housing needs which may be explored through examination, where the evidence is put to the Inspector. Positive Preparations 10 There are also areas with pre-NPPF adopted Core Strategies continuing to rely on Regional Strategy based housing targets, and therefore 5 year land supply positions, in the face of higher needs; the so-called ‘Zombie Plans’ as they live on despite potentially being out-of-date and effectively dead. Sevenoaks is the most obvious example, losing a spate of housing appeals in early 2014 as the housing policies, including the requirement, in the plan were “not up-to-date with the approach now put forward in the NPPF.” Using the typologies as a basis for reviewing any Plan’s effectiveness, the focus should be on the requirement for robust, adequate, up-to-date and relevant evidence on housing needs and constraints to delivery. These are an integral part of the Plan making process so participants can actively engage in its examination to achieve positive outcomes. ‘Positive Preparations’ ‘Underbounded Growers’ Evidenced full needs and seeking to meet them head on. Unmet needs, but already built up to the boundary or constraints. Strategy Risks: Demonstrating deliverability and right spatial strategy. Strategy Risks: Leave no stone unturned in finding opportunities to meet needs. Example: Chesterfield Example: Brighton ‘Squeezed Inbetweeners’ ‘Unbalanced Strategies’ Unconstrained locations, near constrained growth areas, which have to respond to pressures. Economically ambitious but without the housing to support it. Strategy Risks: Demonstrating the Duty to Cooperate with neighbouring authorities Strategy Risks: Misalignment between jobs and homes. Example: Aylesbury Vale Example: South Worcestershire ‘Lacking Evidence’ Out-of-date, insubstantial or no evidence on objectively assessed housing needs. Strategy Risks: Not justfied by the evidence. Example: West Northamptonshire ‘Defer the Pain’ Chasing an ‘early review’ as a solution to unmet needs, with the hope of future change in evidence/ politics. Strategy Risks: Early review as a panacea for an unsound plan. Example: Dacorum ‘Pleading Constraints’ Accepting needs but praying in aid of constraints (e.g. Green Belt, SPA, AONB, Infrastructure, Countryside). Strategy Risks: Constraint led approach leading to unmet needs in the market area. Duty to Cooperate. ‘Zombie Plans’ High housing needs, but no new Local Plan on the horizon and reliance on a pre-NPPF Core Strategy. Strategy Risks: Weakened defence on appeals Example: Sevenoaks Example: Reigate and Banstead Figure 8: Local Plan Typologies Positive Preparations 11 Date Submitted Jan-14 Jan-14 Dec-13 Dec-13 Dec-13 Dec-13 Dec-13 Dec-13 Dec-13 Dec-13 Dec-13 Nov-13 Oct-13 Oct-13 Oct-13 Oct-13 Oct-13 Sep-13 Aug-13 Aug-13 Aug-13 Aug-13 Jul-13 Jul-13 Jul-13 Jun-13 Jun-13 Jun-13 Jun-13 Cherwell Runnymede Amber Valley Cheshire West and Chester Charnwood Southampton Stroud Ashfield Bolsover Mendip Bury Leicester Colchester Allerdale Lincoln North Kesteven West Lindsey Fenland East Cambridgeshire Stafford Aylesbury Vale East Devon Thurrock Mid Sussex Knowsley Metropolitan Swindon Brighton & Hove North West Leicestershire West Dorset (Joint West Dorset, Weymouth & Portland) 12 LPA Ongoing Withdrawn Ongoing Ongoing Ongoing Ongoing Ongoing Ongoing Withdrawn Ongoing Ongoing Ongoing Withdrawn Withdrawn Withdrawn Ongoing Ongoing Ongoing Ongoing Ongoing Ongoing Ongoing Ongoing Ongoing Ongoing Ongoing Ongoing Ongoing Ongoing Outcome ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ Date Time from Found Submission to Sound Found Sound (months) South West East Midlands South East South West North West South East East of England South West South East West Midlands East of England East of England East Midlands East Midlands East Midlands North West East of England East Midlands North West South West East Midlands East Midlands South West South East East Midlands North West East Midlands South East South East Region 625 510 570 1800 450 855 950 855 1345 550 430 510 480 560 990 267 830 1280 500 415 400 560 455 815 790 1317 510 286 670 RS Target (p.a.) Benchmark Appendix 1 - Table of Local Plans Submitted for Examination Against NPPF Year 2 of NPPF Positive Preparations Planned Provision 419 310 798 1354 241 543 909 555 988 417 796 693 524 581 119 130 1220 701 626 421 222 394 406 779 880 496 460 568 688 482 510 565 1250 450 411 950 749 675 500 495 550 2253 304 830 1280 400 415 300 482 380 795 790 1100 470 220 670 ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ CLG HH Submission Sound/ Proj (p.a.)* Target Adopted Target -143 0 -5 -550 0 -444 0 -106 -670 -50 65 40 -480 -560 1263 37 0 0 -100 0 -100 -78 -75 -20 0 -217 -40 -66 0 Proposed Reduction on RS Increase/Decrease 63 200 -233 -104 209 -132 41 194 -313 83 -301 -143 -524 -581 2134 174 -390 579 -226 -6 78 88 -26 16 -90 604 10 -348 -18 ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ Outcome Outcome Against Against Proposed RS HH Reduction Against HH ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ Change After Submission Ongoing Ongoing Ongoing Ongoing Ongoing Ongoing Ongoing Ongoing Ongoing Sound Withdrawn Jun-13 Jun-13 Jun-13 Jun-13 May-13 May-13 May-13 May-13 May-13 May-13 Apr-13 Apr-13 Apr-13 Broxtowe (Aligned Core Strategy) Gedling (Aligned Core Strategy) Nottingham(Aligned Core Strategy) Rochdale Malvern Hills (South Worcestershire Development Plan) Worcester (South Worcestershire Development Plan) Wychavon (South Worcestershire Development Plan) Gravesham Ongoing ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ Oct-13 6.5 ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ Yorkshire & Humber East of England Yorkshire & Humber South East West Midlands West Midlands West Midlands North West West Midlands Yorkshire & Humber East Midlands East Midlands East Midlands South West South West South West 1700 700 4300 465 475 175 250 400 290 1160 1000 400 340 1338 795 280 1101 659 4082 481 384 202 240 322 232 544 1143 357 414 1449.7 511 153 1545 800 4375 271 370 229 204 400 241 850 1009 426 362 700 620 179 ~ 800 ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ -155 100 75 -194 -105 54 -46 0 -49 -310 9 26 22 -638 -175 -101 ** subject to immediate/early review of Local Plan, including housing target *Benchmarked against relevant CLG HH projections base for examination period. Plans submitted for examination in Year 1 of the NPPF were benchmarked against CLG 2008 HH Proj (08-33). Plans submitted for examination in Year 2 of the NPPF were benchmarked against CLG 2011 HH Proj (p.a. 11-21) Kirklees Chelmsford Leeds Cannock Chase Rotherham Ongoing Jun-13 Ongoing Ongoing Jun-13 Ongoing Jun-13 North Somerset Weymouth and Portland (Joint West Dorset, Weymouth & Portland) Teignbridge Positive Preparations 13 444 141 293 -210 -14 27 -36 78 9 306 -134 69 -52 -750 109 26 ~ 100 ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 141 ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ +0 ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ Mar-13 Mar-13 Feb-13 Feb-13 Feb-13 Feb-13 Feb-13 Jan-13 Jan-13 Dec-12 Dec-12 Dec-12 Nov-12 Nov-12 Mar-13 Nov-12 Oct-12 Oct-12 Oct-12 Oct-12 Oct-12 Sep-12 Sep-12 Sep-12 Sep-12 Sep-12 Sep-12 Jul-12 Jul-12 Jun-12 Jun-12 Christchurch East Dorset Richmondshire North Warwickshire Broadland (Joint Revision) Norwich (Joint Revision) South Norfolk (Joint Revision) Waverley South Somerset Daventry (South Northants JCS) Northampton (South Northants JCS) South Northamptonshire (South Northants JCS) Erewash Tamworth Hart Babergh Copeland Hastings Rushcliffe West Lancashire Coventry Chesterfield Melton Ribble Valley Warrington Solihull Staffordshire Moorlands Rother Wiltshire Hartlepool Dacorum Date Submitted Mar-13 14 Lichfield LPA Year 1 of NPPF Positive Preparations Sound Withdrawn Ongoing Ongoing Sound Sound Ongoing Ongoing Withdrawn Sound Withdrawn Sound Ongoing Sound Sound Sound Withdrawn Withdrawn Sound Ongoing Ongoing Ongoing Ongoing Withdrawn Sound Sound Sound Ongoing Ongoing Ongoing Ongoing Ongoing Outcome ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 10.9 ~ 10.9 ~ ~ ~ ~ ~ ~ Jul-13 12.6 ~ ~ ~ Jan-14 15.7 Nov-13 14.0 ~ ~ ~ Jun-13 8.7 ~ Sep13 ~ Oct-13 11.7 Sep13 Jan-14 14.3 ~ ~ Jan-14 13.5 ~ ~ ~ ~ ~ Nov-13 9.3 Nov-13 9.3 Nov-13 9.3 ~ ~ ~ ~ ~ Date Time from Found Submission to Sound Found Sound (months) East of England North East South West South East West Midlands West Midlands North West North West East Midlands East Midlands West Midlands North West East Midlands South East North West East of England South East West Midlands East Midlands East Midlands East Midlands East Midlands South West South East East of England East of England East of England West Midlands Yorkshire & Humber South West South West West Midlands Region 600 395 1900 280 300 435 380 161 170 380 740 300 750 210 230 280 220 145 360 2485 985 250 560 705 610 150 200 320 173 450 RS Target (p.a.) Benchmark 520 280 2160 560 280 640 840 240 160 360 1200 240 520 360 240 400 400 200 360 520 1480 400 800 440 720 1000 680 250 200 320 200 440 430 320 1850 218 275 500 500 200 170 380 669 310 553 200 230 300 236 205 368 373 1527 353 830 230 862 477 706 164 180 294 225 435 430** ~ ~ ~ 300 500 ~ ~ ~ 380 ~ 310 ~ 214 230 300 ~ ~ 368 ~ ~ ~ ~ ~ 862 477 706 ~ ~ ~ ~ ~ CLG HH Submission Sound/ Proj (p.a.)* Target Adopted Target Planned Provision -170 -75 -50 -62 -25 65 120 39 0 0 -71 10 -197 -10 0 20 16 60 8 373 1527 -2132 -155 -20 302 -228 96 14 -20 -26 52 -15 Proposed Reduction on RS Increase/Decrease -90 40 -310 -342 -5 -140 -340 -40 10 20 -531 70 33 -160 -10 -100 -164 5 8 -147 47 -47 30 -210 142 -523 26 -86 -20 -26 25 -5 Proposed Reduction Against HH -170 ~ ~ ~ 0 65 ~ ~ ~ 0 ~ 10 ~ 4 0 20 ~ ~ 8 ~ ~ ~ ~ ~ 302 -228 96 ~ ~ ~ ~ ~ -90 ~ ~ ~ 20 -140 ~ ~ ~ 20 ~ 70 ~ -146 -10 -100 ~ ~ 8 ~ ~ ~ ~ ~ 142 -523 26 ~ ~ ~ ~ ~ Outcome Outcome Against Against RS HH +0 ~ ~ ~ +25 +0 ~ ~ ~ +0 +0 ~ +14 +0 +0 ~ ~ +0 ~ ~ ~ ~ ~ +0 +0 +0 ~ ~ ~ ~ ~ Change After Submission Ongoing Withdrawn Sound Sound Sound Sound Sound Sound Withdrawn Sound Sound Sound Withdrawn Sound Sound Sound Sound Sound Sound Sound Sound Sound Sound Sound Sound Sound Sound May-12 May-12 May-12 May-12 May-12 Mar-12 Feb-12 Feb-12 Feb-12 Jan-12 Jan-12 Jan-12 Jan-12 Dec-11 Nov-11 Nov-11 Sep-11 Sep-11 Sep-11 Aug-11 May-11 May-11 May-11 Mar-11 Mar-11 Mar-11 Mar-11 Mar-11 Mar-11 Apr-10 Suffolk Coastal Mid Suffolk (Focussed Review) Selby Bath & North East Somerset Chorley (Central Lancashire JCS) Preston (Central Lancashire JCS) South Ribble (Central Lancashire JCS) 15 Sound Sound ~ ~ 6.2 9.8 ~ ~ 26.9 Jul-12 26.8 May13 Nov-13 31.5 Oct-12 19.2 Jun-12 14.3 Jun-12 14.3 Jun-12 14.3 ~ Jun-13 25.5 Oct-12 16.1 Oct-12 14.9 Aug-13 23.4 Oct-12 13.3 Oct-12 12.7 Jul-12 7.6 Aug-12 9.5 Jul-12 7.2 ~ Oct-12 9.2 Jun-13 16.3 Nov-12 9.7 ~ Dec12 Nov-12 8.7 Sep12 Jun-13 12.9 Aug-13 14.8 Jan-14 20.4 ~ ~ Feb-13 8.2 Feb-13 7.8 South East South East South West South East North West North West North West South West Yorkshire & Humber North West South East North West West Midlands North West South West South West South East Yorkshire & Humber South West South East South East South East East of England East of England East of England East of England Yorkshire & Humber South East North West South East East Midlands South East 525 2068 1640 547 417 507 417 1065 440 570 550 978 175 500 1090 805 292 1150 258 290 240 815 250 260 415 510 200 500 1600 535 380 612 889 1560 1600 440 400 400 360 800 520 360 680 880 200 280 520 440 400 1560 160 560 680 880 480 400 640 1000 240 840 1080 400 360 520 525 1750 1610 547 334 406 334 575 440 570 410 1000 175 500 850 730 292 1088 120 350 240 815 237 260 415 446 200 460 1300 442 365 550 525** 1750** 1692** 547 417 507 417 ~ 450 570 450** 1000 175 552 850 730** 292 ~ 120** 400 240 ~ 260** 260 415 465** 200** 460 ~ ~ 380 625 0 -318 -30 0 -83 -101 -83 -490 0 0 -140 22 0 0 -240 -75 0 -62 -138 60 0 0 -13 0 0 -64 0 -40 -300 -93 -15 -62 ** subject to immediate/early review of Local Plan, including housing target *Benchmarked against relevant CLG HH projections base for examination period. Plans submitted for examination in Year 1 of the NPPF were benchmarked against CLG 2008 HH Proj (08-33). Plans submitted for examination in Year 2 of the NPPF were benchmarked against CLG 2011 HH Proj (p.a. 11-21) West Berkshire Milton Keynes South Gloucestershire South Oxfordshire St Helens Metropolitan Wealden District Wigan Metropolitan South Staffordshire Halton Borough Taunton Deane Bournemouth Woking Kingston upon Hull Purbeck Shepway Eastbourne Medway Hertsmere Watford Ryedale Reigate & Banstead Salford East Hampshire Ongoing Sound Jun-12 Blaby Sound Jun-12 Winchester Positive Preparations -364 190 10 107 -66 6 -26 -225 -80 210 -270 120 -25 220 330 290 -108 -472 -40 -210 -440 -65 -243 -140 -225 -554 -40 -380 220 42 5 30 0 -318 52 0 0 0 0 ~ 10 0 -100 22 0 52 -240 -75 0 ~ -138 110 0 ~ 10 0 0 -45 0 -40 ~ ~ 0 13 -364 190 92 107 17 107 57 ~ -70 210 -230 120 -25 272 330 290 -108 ~ -40 -160 -440 ~ -220 -140 -225 -535 -40 -380 ~ ~ 20 105 +0 +0 +82 +0 +83 +101 +83 ~ +10 +0 +40 +0 +0 +52 +0 +0 +0 ~ +0 +50 +0 ~ +23 +0 +0 +19 +0 +0 ~ ~ +15 +75 Positive Preparations 16 About NLP Nathaniel Lichfield & Partners (NLP) is an independent planning, economics and urban design consultancy, with offices in Cardiff, Leeds, London, Manchester and Newcastle. 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